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JPM v. Palm Beach County School Board

916 F. Supp. 2d 1314 (2013)

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JPM v. Palm Beach County School Board

United States District Court for the Southern District of Florida
916 F. Supp. 2d 1314 (2013)

Facts

CM was a special-education student with profound developmental disabilities in the Palm Beach County School District (district) (defendant). Beginning in the sixth grade and continuing into the seventh grade, CM developed severe behavioral issues and would often try to physically harm either himself or others. During this time, school staff members frequently physically restrained CM. Most of the time, staff members used restraint techniques of the Professional Management Crisis Association, as preferred by district policy. On at least one occasion, however, staff members restrained CM using TEAM techniques, which were usually reserved for use by school police in emergency safety situations. School records showed that any use of restraint techniques was always in response to CM’s problematic behavior and never as punishment. Two doctors later diagnosed CM with post-traumatic stress disorder, citing the traumatizing event as CM’s experience being restrained by school staff. CM’s parents (plaintiffs) sued the district in district court, alleging, among other counts, a violation of § 504 of the Rehabilitation Act. The district moved for summary judgment.

Rule of Law

Issue

Holding and Reasoning (Marra, J.)

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